07 August 2009

Did EPA Stack its Ethanol Life-Cycle Analysis Peer Review?

The EPA has just released a set of expert peer review reports under the heading of Renewable Fuel Standard Program (RFS2) Lifecycle Greenhouse Gas (GHG) Analysis. The life-cycle analysis of renewable fuels is a political hot button, for reasons that I have discuss here and here and here. For this post the important thing to be aware of is that the Obama Administration has proposed a life-cycle approach to counting the greenhouse gas emissions from ethanol.

Here I focus on the report titled Lifecycle Greenhouse Gas Emissions due to Increased Biofuel Production: Methods and Approaches to Account for Lifecycle Greenhouse Gas Emissions from Biofuels Production Over Time (PDF). The study was conducted by a consulting firm called ICF International, which has a $21 million contract from EPA for technical assistance. The study concluded overall that:

Most peer reviewers generally agreed that the approach taken by EPA was scientifically objective.

The report notes that there was some difference of opinion among the reviewers about the details of the review. However, despite these technical issues of disagreement, the report asserts that EPA's proposed methodology has passed peer review.

Taking a look at the five experts on the EPA peer review panel shows that three are from environmental organizations that have called for a life-cycle analysis of corn ethanol (WRI, UCS, and TNC) and a fourth is an independent consultant who is primarily working with another environmental advocacy group that has also called for a life-cycle analysis of corn ethanol (ED). The fifth peer reviewer is a former employee of ICF (see CVs appended to report).

So 4 of 5 peer reviewers are employed by advocacy groups with established positions on the topic under review, and these position support that of the Obama Administration's EPA. At a minimum this situation creates a whale of an appearance problem, regardless of the scientific qualifications of the peer reviewers (which I am not at all discussing in this post).

For its part EPA and ICF claim in the report that:

the contractor and EPA determined that there were no direct and substantial COI or appearance of impartiality issues that would have prevented a peer reviewer’s comments from being considered by EPA.

This assertion does not pass a basic credulity test. The committee sure looks like it has members with strong biases falling in one direction and these biases may even rise to the level of a conflict of interest. The fact that the peer review resulted in support for the EPA was in fact conducted by a consulting firm paid tens of millions from EPA adds another layer of bad appearance.

How does an agency avoid such problems in the empanelment of scientific advisors?

Well, they should start by reading our BPC report issued this week (here in PDF), which tackles exactly these sorts of issues.